Description:

Below is a summary and highlights of findings for the Hospital Inpatient Quality Reporting (IQR) program electronic clinical quality measure (eCQM) requirements as proposed in the FY 2017 IPPS Proposed Rule, subject to change with publication of final rule due out by August 1, 2016.

The Hospital Inpatient Prospective Payment System (IPPS) proposed rule covers proposed policy changes and Fiscal Year (FY) 2017 Medicare reimbursement rates. For FY 2017, the increase to the market basket payment rate is 2.8 percent. The rule was filed on April 18, 2016 and will be published in the Federal Register on April 29, 2016. Comments are due by June 17, 2016, and the final rule will be issued by August 1, 2016.

Included in the regulation are proposed changes to the IQR program and other quality reporting programs. Encore’s review focused on the clinical quality measurement for eligible hospitals (EHs) and critical access hospitals (CAHs) participating in the IQR and Meaningful Use (MU) programs in 2017. The Hospital Value-Based Purchasing (VBP) program section was also reviewed for any eCQM updates.

Below are the most significant findings and proposed changes.

Key Finding – Results of the 2015 Validation Pilot Test

The most significant finding includes the results of the 2015 validation pilot test for electronic clinical quality measures (eCQMs). CMS previously stated they had anecdotal comments about performance level differences between chart-abstracted and eCQM data, but they did not have sufficient data to confirm or refute the accuracy of those comments. The results of the pilot test yielded measure record matching rates (the rates of medical record abstracted values as compared to the values reported in the EHR Quality Reporting Document Architecture Category I, QRDA I, file) of less than 50 percent for all the measures reported. For all measures, the inconsistencies between abstracted values and values reported in the QRDA I files appear to be mainly due to missing data rather than actual differences in reported versus abstracted values.

The most significant change to electronic reporting is the proposed removal of 13 eCQMs and the requirement to electronically report the remaining 15 eCQMs in the 2017 reporting year. This would change the total number of eCQMs from 28 to 15 and the reporting requirement from 4 eCQMs to 15. This applies to both the IQR and MU programs for electronic submission of the eCQMs. However, for the 2017 reporting year, hospitals can still attest to 16 eCQMs under the MU programs. The additional eCQM is the ED-3 measure, which is not applicable for IQR as it is considered an outpatient measure.

The other proposed reporting change is the requirement to report a full calendar year of data for all eCQMs in the Hospital IQR Program measure set for the Calendar Year (CY) 2017 reporting period. This is a change from reporting only one quarter of data from Q3 or Q4 in 2016. The eCQM data would be submitted by the end of two months following the close of the calendar year, by February 28, 2018.

For the three remaining measures, chart abstracted and eCQMs (ED-1, ED-2, and PC-01), CMS proposes to continue its policy that hospitals must submit a full year of chart-abstracted data in addition to electronic submission. However, data submission for the chart abstracted version of the measures would continue to be submitted on a quarterly basis rather than the annual eCQM requirement.

CMS did not propose a change to their public reporting policy for eCQMs in 2017. They would not publicly report eCQMs and they would continue to only use chart-abstracted results for the Hospital VBP program.

Based on the pilot validation findings as stated previously, CMS is proposing to modify the existing validation process for Hospital IQR program data to include validation of eCQMs beginning with the FY 2020 payment determination year. They are proposing to include eCQM validation of up to 200 randomly selected hospitals. These hospitals would be required to submit timely and complete medical record information from the EHR for at least 75 percent of sampled records, but they would not be scored on the basis of measure accuracy for FY 2020 payment determinations. To align with the chart-abstracted validation process, CMS is proposing to reimburse the randomly selected hospitals at a rate of $3.00 per chart for submitting charts electronically via Secure File Transfer (SFT). Hospitals that pass eCQM validation requirements would receive their full annual payment update, assuming all other Hospital IQR program requirements are met. Hospitals that fail to submit timely and complete data for 75 percent of requested records for eCQM validation would not receive their full annual payment update.

CMS is also proposing to update its Extraordinary Circumstances Extensions or Exemptions(ECE) policy by establishing a separate submission deadline of April 1 following the end of the reporting calendar year for ECEs related to eCQMs beginning April 1, 2017.

Key Implications to Hospitals

The requirement for submission proposed as a full year of data for 15 eCQMs means hospitals have a limited timeline for making sure their workflow and EHR support reporting of all the proposed eCQMs.

There is evidence of inconsistency between abstract values and values reported in the QRDA files; hospitals need to allocate time and resources to assess and optimize their EHR and associated workflows in order to improve their eCQM measure performance.

Questions/Comments

Points of view and interpretation were relevant at time of authorship; however, they are subject to change over time.

Encore’s eMeasure Research and Review Board (eMRB) is made up of Encore’s industry thought leaders and eMeasure experts who are responsible for understanding the current state and future direction of quality and value-based programs for our business. In order to communicate relevant information to our consultants and our clients, eMRB produces periodic InfoAlerts, which provide information on recent and important news.